The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million

Among the breaches identified, the Committee held that the asset management company Altaroc Partners (formerly Amboise Partners SA) did not have operational procedures governing the investment and divestment process of the funds under management. In this respect, it found that Altaroc Partners had failed to check that the entities that had granted loans to the funds under management were authorised to carry out such transactions, and therefore that it had not conducted its business as an asset management company honestly, fairly and professionally, or with the requisite skill, care and diligence.

The Committee also noted a number of shortcomings in the funds' marketing materials.

It further found that the asset management company was unable to prove that the retrocession of management fees to distributors for the marketing of funds in its Altaroc Global range had had the effect of enhancing the quality of service provided to clients.

It also held that the asset management company had not systematically carried out the requisite due diligence in terms of anti-money laundering and combating the financing of terrorism on the assets and liabilities of the funds concerned.

Finally, the Committee considered that the breaches committed by the company were attributable to Mr Tchenio and Mr de Giovanni.

An appeal may be lodged against this decision.

About the Enforcement Committee
The Enforcement Committee, which is made up of judges and professionals, has total freedom to make decisions. It can impose sanctions on any person or company whose practices contravene laws and regulations that fall within the jurisdiction of the AMF. It ratifies settlement agreements signed by the Secretary General and respondents. And it takes part in the AMF’s educational efforts by clarifying financial regulations when explaining its decisions.